RMD waiver in 2020

[shydig]

I inherited an IRA from my father in early 2020 and it falls under the 10 year rule.  He was already taking RMDs before he passed away.  The IRS waived the RMD requirement for 2020 and I didn't make an RMD that year.  Does the RMD waiver in 2020 expand my withdrawal window from 10 years to 11 years?  Do I have until 12/31/31 to drain the account?

[rjs]

No, the waiver for 2020 does not extend the 10-year window. You still must empty the account "by December 31 of the year containing the 10th anniversary of the owner's death." Since your father passed away in 2020, that means you must empty the account by December 31, 2030.

[dmertz · Accepted solution]

It was your father, not you, who had no RMD for 2020.  Because your father had no RMD for 2020, there was no year-of-death RMD for you to complete on behalf of your father.  Because your father died in 2020, your first year as beneficiary under the 10-year rule was 2021 (not 2020), with 2030 being the 10th year.  The account must be fully drained by the end of 2030.

Because your father died after his required beginning date for RMDs, the proposed regulations require you to take annual RMDs under the 10-year rule.  However, the IRS has waived through 2024 the penalty for not taking these beneficiary RMDs under the 10-year rule.

[shydig]

Thank you.  Those are the assumptions I've been working under.